Tribunal held that the royalty was paid for basket of services . accordingly adjustment is held to be not justified . As regards advertising, marketing and promotion of sales expenses there being no proof of existence of International Transaction adjustment made in respect of advertising marketing and promotion of sales expenses to be deleted . As regards expenses reimbursed matter remanded to the AO for verification .( AY.2010-11, 2011-12)
Reckitt Benckiser (I.) Pvt. Ltd. v Dy. CIT (2020) 81 ITR 577 (Kol) (Trib)
S.92C: : Transfer pricing – Arm’s length price – Royalty -Paid for basket of services — Adjustment is held to be not justified -Advertising, marketing and promotion of sales expenses —No proof of existence of International Transaction —Adjustment made in respect of advertising marketing and promotion of sales expenses to be deleted -Expenses reimbursed matter remanded [ S.92CA ]